CAO 100.66 – Maintenance authorities — EASA equivalents
Details of the legislation
CAO 100.66 provides a means for a Recognised Organisation (RO) to provide training which will lead to a CASR Part 66 equivalent licence outcome. This is achieved using the current powers of CAR 33B and the new CAO 100.66. Adoption of this transitional arrangement of the European Aviation Safety Agency (EASA)-like licence and training outcomes is purely a voluntary option.
Potential applicants for a CAO 100.66 authority can be initial applicants or current CAR 31 Licensed Aircraft Maintenance Engineers (LAME). ROs will be able to apply recognition of prior learning principles to a potential applicant's situation. This allows a RO to determine and deliver any training shortfall to allow the potential applicant to achieve an EASA-like A, B1 or B2 Category result under CAO 100.66.
CAO 100.66 requires that the Airworthiness Authority applicant provides CASA with a statement from a RO that they have achieved a Category A, B1 or B2 outcome. Personnel who have gained the knowledge and competency requirements included in the CAO 100.66 may apply to CASA to gain EASA-like Categories A, B1 and B2. CASA would then issue an Airworthiness Authority for Maintenance commonly known as a “Maintenance Authority” (MA) to the individual in the Category A, B1 or B2 being applied for. The policy for Category A, B1 or B2 rated maintenance authorities during the period of operation for CAO 100.66 is not to issue them with limitations. There are however, some minor exceptions for matters such as propellers, wooden structures, fabric and composites.
The MEA07 training package delivers sufficient training to avionics personnel to also provide them with a limited B1 category outcome. Where a B2 holder has also been issued a limited B1 authority, then completion of instrument of electrical maintenance on aircraft systems designated structure, powerplant or mechanical is allowed.
CAO 100.66 allows a B1 or B2 EASA-like authority holder to sign for and supervise work on the aircraft categories (mechanical or avionic) and ratings for which it has been endorsed. An A Category holder can certify for work within the scope of the A Category that the holder has personally performed.
For the purposes of the CAO 100.66, a person must have an appropriate rating endorsed on their B1, limited B1 or B2 MA if the holder is to carry out maintenance on an aircraft/engine combination, or on an engine, for large aircraft, complex aircraft or listed aircraft. Generally, a large aircraft means an aeroplane with a maximum take-off weight (MTOW) of more than 5 700 kg, or a helicopter that is multi-engined. A complex aircraft means one that CASA lists as such in Airworthiness Advisory Circular (AAC) 9-66 after considering that it should be included in the list by virtue of various aviation complexity factors. A listed aircraft is one that CASA lists as such in AAC 9-66 because CASA considers that type training would enhance safety, taking into account issues such as complexity, new technology, Australian Transport Safety Bureau (ATSB) recommendations or other safety issues.
To gain a type specific rating for a B1 or B2 authority, the applicant would also need to supply CASA with evidence of completing the applicable B1 or B2 specific type training course. CAO 100.66 works in combination with the existing Civil Aviation Regulations (1988) for maintenance. It is possible for a LAME to hold both a CAR 31 licence and an MA.
The new parallel licence structure
Privileges of the MA
The CAO 100.66 sets out, for each of the categories or subcategories of authority, the privileges that the holder may exercise. A key privilege is that of issuing the certificate of release to service for the relevant aircraft. Under the CAO 100.66, the certificate of release to service has the same meaning as certification of completion of maintenance on aircraft in Australian territory issued under regulation 42ZE of CAR 1988. The CAO 100.66 delivers EASA-like Category A, B1 and B2 MA outcomes. There are four sub-categories which are applicable to the A and B1 authorities as follows:
- A1 and B1.1 = fixed wing aeroplane with turbine engine
- A2 and B1.2 = fixed wing aeroplane with piston engine
- A3 and B1.3 = helicopter with turbine engine
- A4 and B1.4 = helicopter with piston engine.
Privileges of Category A
The holder of an authority in subcategory A1, A2, A3 or A4 who has been type and task trained and then authorised by the CAR 30 organisation maintaining the aircraft, may issue a certificate of release to service for a class A aircraft and certain class B aircraft following completion of specific and limited maintenance activities mentioned in CAO 100.66 Appendix 1. These authorities are not endorsed with specific aircraft type ratings by CASA.
Privileges of Category B1
The holder of an authority in subcategory B1.1, B1.2, B1.3, or B1.4 may issue a certificate of release to service after completion of maintenance on aircraft structure, powerplant, mechanical and electrical systems including replacement of avionic line replaceable units whose correct functioning and serviceability can be demonstrated by use of a simple test. They may undertake any work in the subcategory of Category A that applies to the holder. They may supervise others and requires a rating for type-rated aircraft.
Privileges of a Limited Category B1
Where a B2 holder has also been issued with a limited B1 authority, then completion of instrument or electrical maintenance on aircraft systems designated structures, powerplant or mechanical is allowed. A letter explaining the introduction of Limited B1 has been sent to all B2 and quality assurance managers for all organisations which explains the scope of the CAO 100.66 Maintenance Authority.
Privileges of Category B2
The holder of an authority in Category B2 may issue a certificate of release to service following completion of maintenance on aircraft systems designated avionic or electrical systems. They may supervise others and requires a rating for type-rated aircraft.
Eligibility
To be eligible for an MA, the applicant must be at least 21 years of age, be able to communicate effectively in the English language, meet airworthiness management requirements, not suffer from a relevant disability, meet the knowledge, experience and competency requirements that are relevant for the authority or rating and be employed by (or in an arrangement with) a person (a CAR 30 organisation) who holds a CASA certificate of approval under regulation 30 of CAR 1988 to carry out maintenance covering the aircraft.
Continued validity of an authority
An MA is valid for 5 years and may be revalidated by means of a validation process.
Recency
For all MA holders, there is a recency requirement. To exercise the relevant privileges of their authority, they must, in the previous 2 years, have had at least 6 months' experience in inspecting or maintaining aircraft structures, power-plant, mechanical, electrical or avionic systems, or, during that 2 year period, have first become qualified for the issue of the authority.
Conditions
An MA is issued under the CAO 100.66 subject to the condition that the holder must comply with the requirements of the CAO 100.66 for holding an MA and exercising its privileges. Similarly, the holder must comply with the requirements of the CAO 100.66 for the endorsement of a rating, if any, on the authority. It is also a condition that if he or she is suffering from a disability that is likely to affect the exercise of the privileges of the authority, he or she must tell CASA in writing within 14 days of first learning of the disability.
Supervision
CAR 42ZC (3)(b)(ii) and (4) (c) (i) permit an AME to work under the supervision of a LAME on Class A and B aircraft respectively; but do not provide for MA holders to supervise AME. Supervision permissions for CAO 100.66 MA holders has been achieved using the CAR 42ZC (6) power to authorise a person to physically do maintenance as per CAR 42ZC (3)(d) and CAR 42ZC (4)(e). This supervision capability only applies to holders of a CAO 100.66 category B1 or B2 MA.
CAO 100.66 states that for the purpose of paragraphs CAR 42ZC (3) (d) and CAR 42ZC (4) (e), and clause 10 of CAO 100.66 that a person under supervision is authorised to perform maintenance. That provision is present to allow the B1 or B2 MA holder to supervise an AME. CAR 42ZC (6) is the head of power for this provision.
CAO 100.66 provides that a holder who supervises a person who performs maintenance in accordance with this clause, is exempt from the requirement to comply with paragraph CAR 42ZE (1) (b); specifically, paragraph 1.3 of Schedule 6 of CAR 1988.
Without detailed reference to those provisions the reader may find it difficult to interpret that section of the CAO 100.66. The provisions are in place to allow an AME to perform maintenance under the supervision of a B1 or B2 MA holder as applicable and allow the B1 or B2 MA holder to certify for the maintenance under Schedule 6.
Requirements for award of a Category
To be awarded a particular Category of MA, the person must demonstrate by examination (with a pass mark of 75%), knowledge of specified subjects to specified levels, as set out in Appendix 4 of the CAO 100.66. This examination must be conducted by an RO as defined in Appendix 5 of CAO 100.66. The applicant must also meet detailed practical experience requirements and hold relevant units of competency arising from that experience. These units have their origin in the Australian Quality Training Framework (AQTF) Aeroskills Training Package which is overseen by the relevant training authorities in the States and Territories.
Training and assessment
The training and assessments for an authority must be in accordance with Appendix 4 of the CAO 100.66. The training and assessments for a rating must be in accordance with Appendices 6 and 7 of the CAO 100.66.
Recognised Organisations (RO)
Under the CAO 100.66, only an RO may conduct the training and assessments required for the issue of a basic Category of authority. Appendix 5 of the CAO 100.66 deals with ROs and sets out the circumstances in which CASA will recognise the RO's training and assessments. To be approved by CASA, the prospective RO must apply in writing and provide a detailed exposition.
The exposition describes the organisation and its procedures and facilities and must cover a broad range of information specified in the CAO 100.66 to enable CASA to assess its fitness to perform properly as an RO. The RO must give an undertaking that it will comply with the requirements of Appendix 5 of CAO 100.66. These include delivery to students of training and assessments in accordance with the requirements of the CAO 100.66. They also include compliance with its approved exposition, and provision of appropriate facilities, equipment, expert staff, training materials, records administration and quality management systems. The CAO 100.66 requires a RO to limit the number of students in a training course to 28 for knowledge training, and 15 for practical training.
Appendix 5 of CAO100.66 also sets out the procedures to be followed to secure the integrity of assessment materials and to deal with cheating or misconduct in assessments. CASA may give an RO directions about its operations. Failure to comply with its undertaking, its exposition, the CAO100.66 or directions given to it by CASA could result in suspension or cancellation of the approval and the consequent refusal by CASA to recognise the training and assessment of students as reliable or appropriate for the issue of MAs or ratings.
Australian Quality Training Framework (AQTF)
The AQTF Aeroskills Training Package is the product of collaboration between the relevant training authorities of the Commonwealth, States and Territories. MEA07 has been approved and a link to the training package is available from the MEA07 Aeroskills Training Package page on the CASA website.
Experience and units of competency for categories
Under the Package, for a Category or subcategory of MA, the applicant must have accumulated the relevant number of years of practical maintenance experience. He or she must also hold relevant units of competency as listed in Appendix 6 of the CAO100.66. For these units of competency, prerequisite qualifications may apply. However, a person may be taken to hold the prerequisites by means of recognition of the person's prior learning.
Wooden structures, fabric surfaces and composites
In addition to the units of competency (including the knowledge) that are required for a subcategory B1.1, B1.2, B1.3 or B1.4 MA, an applicant for an MA who wants the privilege to perform maintenance including wooden structures, fabric surfaces or composite material repair must hold each of the optional units of competency listed for that purpose.
Specific practical experience
At least 1 year of the practical maintenance experience required for an initial authority must be maintenance experience on aircraft relevant to the Category or subcategory for which the initial authority is sought, and must be accumulated immediately before making the application for the authority.
Adding a Category or subcategory to the MA
A person who holds an MA and who applies to add a Category or subcategory to it must meet the knowledge and examination requirements for the Category or subcategory, hold the units of competency required and meet the practical experience requirements.
Non-civil aircraft experience
Practical aircraft maintenance experience gained outside a civil aircraft maintenance environment may be recognised if an RO certifies to CASA that the experience is equivalent and that the applicant has sufficient additional civil aircraft maintenance experience.
Recognition of foreign qualifications
An applicant for an MA will be taken to comply with the knowledge, experience and competency requirements if he or she holds an authorisation acceptable to CASA from an International Civil Aviation Organisation (ICAO) compliant state, recently exercised privileges equivalent to those of an MA holder and an RO certifies that he or she meets the knowledge, experience and competency requirements. Similar rules apply for recognition of the qualifications of a foreign company authorisation.
Eligibility for endorsement of a rating
An applicant for a rating must hold the appropriate B1, limited B1 or B2 MA and the relevant practical experience. For example, before applying for the endorsement, he or she must have successfully completed the relevant theoretical elements and practical elements (within the last 2 years) of the required specific type training and assessment. The B2 type course does not cover some aircraft systems to the level of detail that would allow certification priviledges to be extended to electrical and instrument aspects of systems designated mechanical, powerplant and structural. If a B2 category holder attends and passes a combined B1/B2 course then they would be entitled to a type rating against both the B2 category and the limited B1 authority. If the B2/limitedB1 category holder attends a pure B2 type course then they would only get the type rating attached to the B2 category.
Recognition of foreign ratings
An applicant for a rating will also be eligible for it if he or she holds an acceptable ICAO authorisation with a rating endorsed on it that corresponds to the rating sought. There is also a recency requirement — within the 2 years immediately before the application to CASA, the applicant must have exercised, for at least 6 months, privileges under the rating equivalent to those exercised by a holder of the rating. Once again, similar rules apply for recognition of a foreign company authorisation.
Additional ratings
If the holder of an MA endorsed with a rating applies in writing for an additional rating, CASA will endorse the rating on the holder's authority if he or she holds an appropriate B1 or B2 authority and within the 2 years immediately before the application has exercised, for at least 6 months, privileges under the rating that he or she already holds.
There is also a qualification requirement — the applicant must successfully complete the type training and assessment mentioned in the CAO 100.66 for the rating, or have foreign qualifications that CASA recognises for the additional rating.
What CAO 100.66 does not do
CAO 100.66 does not automatically replace or convert CAR 31 licence holders to the new regime – it is a voluntary option.
CAO 100.66 does not introduce the EASA-like Category C licence, which is proposed for introduction with CASR Part 66.
CAO 100.23 and 100.24 MAs continue to apply to persons who apply for, or already hold, MAs specifically under them.
How to start using CAO 100.66
The requirements of an EASA-like MA are both different and greater in some areas than an existing licence issued under CAR 31. Therefore an applicant needs to have these differences in training identified via a process of recognition of prior learning by an RO.
The RO are listed in AAC 9-66. The RO will be able to advise you of the training you are required to undertake and apply recognition of prior learning which will give you advanced standing against some or all of the required training. You will be required to satisfy the additional training requirements required for the Category of MA you intend applying for and on completion will be provided with a certificate by the RO.
Once you have achieved the competencies required for the category, you can apply to CASA for that category using CASA Form 464 and provide the appropriate documents given to you to by the RO.